MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $223,038, $252,490, and $240,727 for fiscal years 1989, 1990, and 1991, respectively. After concessions, we must decide the following issues:
1. Whether petitioner may deduct as management fees $284,300, $699,359, and $738,239 for fiscal years 1989, 1990, and 1991, respectively, as petitioner contends; $57,159, $149,175...
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